So, the cogs of European policy have grinded away in the slow fashion only policy-based cogs can to produce the final form of the revised F-gas regulations, giving the cooling industry a definite set of rules to work to.
And, naturally, since everything is there in black and white, that means there is no room for any more speculation about what the rules might mean to the industry, is there?
If only that were true. Given that what has just been ushered is the biggest prospective shift in industry practice for a generation, the amount of uncertainty about the practical implications is pretty worrying - those folk whose job it is to interpret the regulations for those of us who aren’t fluent in regulatory speak seem to be finding new implications all the time. And when these people are worried, we should all be worried.
I expect, like me, many in the industry breathed a sigh of relief once the more extreme elements of the original proposals had been negotiated away, because the scary prospect of service bans etc had been pushed a decent distance into the future.
But as you will see on page 5 of RAC May (subscribe here), Ray Gluckman is warning the industry not to be lulled into a false sense of security by those dates, because some of the consequences of the new regs are going to hit home far sooner than we might have first thought. Ray emphasises four different elements that will, in his words ‘have an immediate impact’. The key one being that in less than four years the HFC phase down will require a major cut in production, which is set to dramatically affect R404A particularly. But that is only the half of it, as there are also warnings over the new leak-checking and automatic leak detection thresholds, and that is going to hit those hordes of smaller supermarkets and convenience stores that we know are hard to convince about regs – let’s face of it, a good number of them are still stubbornly ignoring the R22 phase out and that is even closer at hand.
Equally as concerning is that Ray Gluckman warns he believes there is still not enough clarity in the regs as they are written. It would be hard enough to move industry hearts and minds if they were completely unambiguous, but grey areas in laws are surely only a recipe for confusion. And we haven’t even mentioned the knock-on effects, such as the much-argued-over implications of using mildly flammable refrigerants. Or for that matter, the lack of regulations that specifically address them.
Thus it is vitally important that the industry gets the issues out in the open – at least now we know what the issues could be, even if we don’t necessarily have ready-made solutions. In a miracle of timing, we have a Question Time devoted to F-Gas scheduled for May 21. When we planned it in January, we knew we would be talking about refrigerant options and about dealing with degrees of flammability. Now, it is clear, there is a lot more to talk about. Do come along – more info on p13 RAC May magazine.